[Rachel's introduction: Most cloned animals are born with serious biological defects. Yet the U.S. Food and Drug Administration is about to approve them as food for humans. This is not precautionary.]

By Lorraine Heller

An FDA risk assessment that is expected to declare meat and milk derived from cloned animals safe for the food supply is currently being reviewed by the government, and is due to be released by the end of the year.

If these documents are finalized, cloned animal products will become part of the food supply, without the requirement for such foods to carry special labeling. And this could result in a backlash of absence claims, with 'clone-free' products starting to appear on supermarket shelves.

However, the move has inspired fierce criticism from consumer advocacy groups, which claim that there is insufficient science to guarantee the safety of products from cloned animals.

There is currently no regulation preventing cloned food from entering the nation's food supply. But the Food and Drug Administration (FDA) has asked clone producers and livestock breeders to voluntarily refrain from introducing food products from clones or their offspring into the food supply until the agency endorses the findings of a National Academy of Science (NAS) report it commissioned in 2002 that declared cloned products safe for human consumption.

The FDA said its draft risk assessment is currently "in the clearance process" and is being reviewed within the department and by other governmental agencies, particularly the US Department of Agriculture (USDA).

The documents are expected to be released by December, said the FDA in a statement last week.

But while the government continues to examine the issue, a number of consumer and industry groups have raised their voices against the approval of such products.

According to public interest group Center for Food Safety (CFS), there is "serious scientific concern about the food safety of products from clones." The group points in particular to a 2004 New England Journal of Medicine report, which stated that "given the available evidence, it may be exceedingly difficult, if not impossible, to generate healthy cloned animals."

However, the FDA said its draft risk assessment drew on over 100 scientific studies. Published in 2003, it concluded that "the current weight of evidence suggests that there are no biological reasons to indicate that consumption of edible products from the clones of cattle, pigs, sheep or goats poses a greater risk than consumption of those products from their non-clone counterparts."

At this stage, one of the main concerns for the industry is a lack of definitive and forceful guidance from the FDA.

"We'd like to avoid going down the same path as twelve years ago after FDA approved rBST (a genetically engineered bovine growth hormone that increases milk production in cows). To this day there are still a lot of different disclaimers being used, which must be accompanied by an asterisk and explanatory text," said Chris Galen of the National Milk Producers Federation (NMPF).

Galen told FoodNavigator-USA.com that the NMPF does not at this time support milk from cloned cows entering the marketplace until FDA determines that this is the same as milk from conventionally bred animals. And when this happens, the agency needs to be proactive and clearly and forcefully specify what claims are allowed, he said.

But other groups are taking a harder stand. Last week, the CFS, along with reproductive rights, animal welfare, and consumer protection organizations, filed a legal petition with the FDA calling for a moratorium on the introduction of food products from cloned animals.

The petition calls for the establishment of mandatory rules for pre- market food safety and environmental review of cloned foods. The petition also calls for the Department of Health and Human Services to establish a federal review committee to advise FDA on the troubling ethical issues raised by animal cloning.

According to CFS, recent polls have shown that Americans would refuse to buy food from cloned animals, and that they have serious concerns about the ethics of animal cloning, with a majority of consumers saying they would not buy cloned food, even if FDA deemed the products safe.

However, according to Dr Mark Richards of KRC Research, "it is hard to predict consumer behavior from polls, especially when they know little about the issue."

"Before the introduction of rBST, experts predicted up to a 20 percent drop in milk consumption. But milk consumption levels were not affected at all," he told FoodNavigator-USA.com.

For the time being, the FDA said that "in the spirit of transparency" it is requesting producers of cloned animal products to continue to refrain from introducing their products into the food supply until there has been an opportunity for public comment and the risk assessment is finalized.

[Rachel's introduction: In April, 2000, the Church of England adopted the precautionary principle to guide its use of church lands for growing genetically modified crops.]

Church of England Ethical Investment Advisory Group Recommends Ethical Framework for Genetically Modified Crop Development

The Church of England Ethical Investment Advisory Group has concluded that the genetic modification of crops is not beyond the range of acceptable human activities but has called for a clear ethical framework for practical applications of the science, whether experimental or commercial. Its approach can be summed up as precautionary but not anti-science. The group considers the potential benefits of genetic modification for humankind to be too great to ignore but does not feel it is yet appropriate to grant tenancies for crop trials on Church land given the uncertainties caused by the lack of an ethical framework.

The group draws an analogy with medical and human genetic research, where the limits of acceptable enquiry are clearly defined by reference to an ethical framework. Setting such boundaries could help to address the public's lack of confidence in genetically modified crops. The current regulatory regime is described by the group as fragmented and it identifies some of the areas of public concern not addressed by it, such as assessment of the potential social benefits and potential indirect long-term effects on health and environment.

The group recommends the Christian principle of the good neighbour as the key to evaluating these factors. Researchers should ask themselves the question "what is the effect on the spiritual and physical well being of others resulting from our actions in pursuit of this science?"

Given the rapid development of the genetic sciences, an ethical framework is vital to provide a blueprint for acceptable behaviour where both moral values and the light of practical experience are guides.

The group advises:

** the adoption of a precautionary principle framework, as set out below;

** where unambiguous scientific proof of cause and effect is not available, it is necessary to act with a duty of care;

** where the benefits of early action are judged to be greater than the likely costs of delay, it is appropriate to take a lead and make public the reason for such action;

** where there is the possibility of irreversible damage to natural life support functions, precautionary action should be taken irrespective of the forgone benefits;

** transparency and accountability should be maintained throughout;

** that public acceptance rests on there being a transparent, independent and robust ethical framework forming part of the regulatory process that sets the boundaries for what constitutes the concept that not all that can be done should be done;

** that the further period of voluntary moratorium on commercial crop growing, affording a "breathing space" in which vital questions can be answered and public confidence can be restored, is welcomed;

** that weighing up the current balance of risk and reward, it reflects prudence and neighbourliness on the part of the Church to exercise some control in the granting of new tenancies to grow genetically modified crops on its land;

** and that, consequently, until further research has been conducted into the ecological risks, new agricultural leases should contain a clause excluding the planting of GM crops on Church land. Applications for tenancies in order to conduct field trials would thereafter be considered in the context of the questions identified by the Group and in the light of continuing reflection.

Contacts: Arun Kataria 0171 898 1622

Notes for editors

The Church's national investing bodies (The Church Commissioners, The Central Board of Finance and the Church of England Pensions Board) co- ordinate and develop ethical investment policy through the Ethical Investment Advisory Group which reports to the General Synod.

[Rachel's introduction: The issue of cell phone towers or antennas -- in Europe, called "masts" -- has roiled the Christian community as churches have been offered lucrative contracts to install cell phone antennas in church steeples. Here the interdenominational Christian Ecology Link advocates a precautionary position.]

The ethos behind Christian Ecology Link's approach is that of "care for one's neighbour" and the "precautionary principle". We believe that the church must demonstrate its responsibility to those who live in the local community, whose health may be threatened by the siting of masts in churches where there are schools or homes nearby.

Decisions concerning whether to site masts in churches should be taken on the basis of the precautionary principle, which requires scientists to demonstrate that there is no significant likelihood of harm arising from the use of a new technology. The onus is on the scientist to demonstrate safety before the new technology is introduced. A &pound;7m research programme on the safety of mobile phones and related technology was launched by the Government in 2001; the results are not yet available.

Despite the financial attraction, we believe that churches should exercise great caution at the present time. Any church that installs a mast should display a notice so that the community is aware of the presence of the mast and individuals have the opportunity to choose an alternative place of worship if concerned about potential health risks.

This is not intended as a comprehensive briefing, but provides references from organisations, scientists and other individuals who have written critically about the subject. The Church of England has a relevant web-site: www.aerials.cofe.anglican.org

1. A report expressing concerns about the health implications appeared in the medical journal The Lancet on 25th November 2000 by Dr. Gerard Hyland of the Department of Physics at the University of Warwick. Dr. Hyland reported his concerns to the Science and Technology Committee of the House of Commons in September 1999 and the Industry, Trade, Research and Energy Committee of the European Parliament in July 2001.

In February 2000 Dr. Hyland reported on research which found that existing safety guidelines failed to consider the possibility of adverse health effects on living organisms in fundamental ways. He highlighted the case of an epileptic child living near a Mast Base Station. The number of seizures increased from two a month to an average of eight a day when close to the mast. He reported a similar pattern with other children suffering from headaches and nosebleeds. He also reported findings of reduced growth in pine trees, chromosomal and reproductive damage in plants and a six-fold increase in chromosome damage in cows. He concluded that the occurrence of adverse health effects in the case of animals indicates that the effects of operating masts are real and not psychosomatic.

2. Dr. Roger Coghill is another scientist who has warned about the dangers of mobile phone telecommunications masts. He has a research laboratory in South Wales. Dr Coghill has studied the effects of electromagnetic radiation on living tissue and has warned that mobile phone radiation can damage the human immune system.

3. The Local Government Association (LGA), in a statement in February 2001, reported Councillor Sir Jeremy Beecham, Chairman of the LGA as saying "There are very real fears among our communities about the health impacts of mobile phone masts. That's why we are calling on the Government to undertake further research into this matter, and to ensure that the monitoring of masts and radioactivity is independent and free of industry bias". Kent County Council has banned the installation of mobile phone masts on its property, a decision made on health grounds, according to reports in Law Direct and the national press. Geoff Wild, Kent County Secretary, said that they had considered that they might be legally liable "if these masts are proved to have an adverse effect on health, and people start seeking compensation".

4. Friends of the Earth Scotland has campaigned against mobile phone masts on health and environmental grounds and has a report that may be obtained from 72, Newhaven Road, Edinburgh, EH6 5QG. Tel: 0131 554 9977. Mast Action UK (MAUK) campaigns to raise public awareness about potential risks from improperly sited masts. They are not against mobile phone technology per se, but against the insensitive siting of masts near to houses, schools and hospitals. Its address is PO Box 312, Waltham Cross, Herts EN7 5ZE. Information is also available from Power Watch. The Ecologist magazine published an article on phone masts in October 2001. Its address is Unit 18, Chelsea Wharf, 15 Lots Road, London SW1O OQJ. See the web-sites

5. Church towers in Italy cannot be used to host mobile-telephone masts, according to a ruling in March 2001 by the Italian Bishops' Conference, the organization that governs the Roman Catholic Church. A circular signed by Bishop Ennio Antonelli, its secretary general, said that use of church buildings for purposes unconnected with worship would violate church law and could jeopardize the fiscal exemptions and other privileges currently granted to churches by the Italian state. The document has been circulated to parish priests throughout the country. The circular said that it would be imprudent to compromise the univocality and visibility of Christian symbols in an increasingly multicultural society and described mobile phone masts as "alien to the sanctity" of churches. Access rights for maintenance men and the dangers of electromagnetic pollution were also cited as reasons for the ban. Those already installed must be dismantled. Directors of Vatican Radio were last year accused of exceeding Italian legal limits on electromagnetic emissions at a transmission centre near Rome.

[Rachel's introduction: "People having even the smallest doubt about e-voting should apply the precautionary principle to elections and demand the use of ballot papers."]

In more than two centuries, no western democracy had any serious trouble arising from using ballot papers (by the way, what's wrong with them?) and to date (2006) most democracies of the world (all except Brazil, India, and USA) use ballot papers to elect their Parliaments and Governments.

However, hardware and software vendors are pressing for the use of electronic voting and governments often endorse it.

Most people see electronic voting as a mere technical evolution of ballot paper voting and therefore, they are confidently waiting for hardware and software that will make electronic elections as secure as remote banking, for example. They probably think voting is a simple transaction by which we add one to the electoral "balance" of our candidate, just the way we add money to someone's bank balance when we use our credit card.

Unfortunately voting is not like banking because votes and financial data differ in the level of the secrecy they require and such intrinsic difference is the very reason why electronic voting is unfit for political elections in democracy and no technology can change this.

To see why electronic voting is not compatible with democracy we need to go through a few basic concepts: In democracy, governmental power is transferred by counting secret votes during elections. To accept such transfer, people and parties must be 100 percent sure that electoral results are fair and square: doubts about the legitimacy of the winner can damage the political life of the country and even bring riots and revolutions.

Votes must be forever secret from everybody because otherwise voters could undergo illicit pressure to vote according to somebody else's will. Criminals (and/or governments and/or politicians) have enough power to compell people to vote in a certain way.

Electoral procedures are obviously setup and managed by large organizations which span all over the country and give contracts to private and public companies.

Many people and/or organizations are interested in falsifying electoral results to maintain or to get the governmental power. They can be highly motivated, well financed, sophisticated, and could be outsiders as well as insiders with full knowledge of the election system. These attackers could be political operatives, voters, vendor personnel, polling place workers, election administrators, foreign countries, international terrorist organizations, or just pranksters.

Sitting governments are in charge of guaranteeing the accuracy of electoral results and the secrecy of votes, but the social groups and the economical powers which are the base of any government have the obvious interest in falsifying electoral results and violating the secrecy of votes to preserve the power. They could also succeed thanks to the complete control they have over the electoral process.

It may sound strange but electronic voting is unfit for elections in democracy due to the above points. Infact, in consequence of them we have that: Absolute vote secrecy (point b) can be accomplished only if votes are collected and stored in such away that nobody can ever be able to link each vote to its voter.

If votes are really anonymous then nobody can verify that any of them is the one its (unknown!) voter actually cast. Verification of electoral results can not be based only upon anonymous votes since they could have been altered by fraud or errors and nobody could ever know it.

The only way to guarantee fairness of elections is that electoral procedures guarantee that each vote really represents its (unknown) elector's will. From the above points, we know we can't blindly trust any organization when dealing with elections, thus we, the people, need to verify all to ourselves that electoral procedures really work as they should!

Fairness of elections can be guaranteed only by electoral procedure open to the active check of the people, the so called democratic control.

Now let's compare paper voting with electronic voting: Ballot paper elections can undergo proper democratic control because humans can check the handling of ballot papers, which are visible and tangible objects. It's not by chance that all democracies always used ballot papers! With them a few votes may get lost, but no foreign country, terrorist group, economical or political power will ever be able to alter the final result of our elections! That's why ballot paper elections are suitable for democracy.

Electronic elections can't undergo proper democratic control because computer procedures are not verifiable by humans as we are not equipped for verifying operations occurring within an electronic machine. Thus, for people who did not program them, computers act just like black boxes and their operations can truly be verified only by knowing the input and comparing the expected output with the actual output.

Unfortunately, due to the secrecy of votes, elections have no known input nor any expected output with which to compare electoral results, thus electronic electoral procedures cannot be verified by humans! This applies to electronic elections independently of any technical solution that could ever be implemented.

Results of any electronic vote are, due to their nature, unverifiable and no technical solution can overcome this fact. To accept electronic electoral results, ordinary people need to have an absolute faith in the accuracy, honesty and security of the whole electoral apparatus (people, software, hardware and networks). This is not possible, thus electronic voting is not compatible with democracy.

It is worthy of attention that the above statement is true whichever technical implementation it's used for voting. In other words, e-vote is unfit to democracy whichever hardware and software it's used.

In fact, let's imagine to have a perfect electronic voting system with all the security, auditing, accountability, meaningful public standards and public evaluations we like. Even in such a very optimistic case, in the end, all the votes would be stored in anonymous records and this unverifiable data, processed by unverifiable electronic procedures, would decide the (unverifiable) winner of the election.

Electronic voting is not a technical, but a SOCIAL PROBLEM! Governments can't demonstrate that electronic voting results are correct, but oppositions have no way to support any claim that fraud or mistakes have occurred.

From another point of view, we can say that when ballot paper elections are held under proper democratic control, the people tally up real votes (ballot papers are hand written by electors and readable by anyone). When ballot papers are publicly counted in the same place as they were voted and when scrutineers are randomly selected citizens (as done in Italy, for example), then who actually counts votes and declares the result of each ballot station is the public, and the central electoral service has the mere role of tallying such results. Thousands of ordinary people across the whole nation guarantee and certify the electoral result.

In e-voting, computers tally up information about the way electors voted (which button they pressed or which part of the screen they touched). Such information is collected and stored in the form of anonymous intangible human-unreadable string of bytes. Votes are "counted" and results declared solely by the "electoral service" which is under the control of the government whose term of office is about to expire. No democratic control is possible over electronic elections.

In other words, for electoral results to be verifiable and votes absolutely secret, votes must be anonymous, tangible, human-readable objects. Nowadays, we face terrorism as one of the most dangerous attack to our democracies. A good goal for terrorists could be the alteration of our electoral processes because if they could delegitimate the ruling power, they would have a great victory against our democracy.

Ballot paper elections are very robust and have no single point of failure: there is NOT a single place which abnormal functioning could lead to the impossibility to declare the winner. Paper elections can be held despite of black outs and interruptions of computer networks. Infact, paper elections have properly worked also when electricity and computer did not even exist.

Electronic elections are based on computer networks and computer centres which are very good targets for terrorists. In fact, a terrorist attack to the network infrastructure, to power distribution lines, or to a computer center could lead to the impossibility to know who is the winner of the election, leaving the country whithout a legitimate Parliament or Government.

Elections may have the wrong winner not only because of fraud, but also because of malfunctions of the technical apparatus involved in the voting. In fact, during real electronic elections, malfunctions occur very often, as you can see in votersunite.org and voterprotect.org. The above sites report thousands of malfunctions occurred during the USA 2004 presidential election.

Electronic vote, carried out via computer and digital links represents a poisoned chalice for technologically advanced countries; it is no exaggeration to say that it threatens to eliminate democracy as we know it today. It's an enticing chalice because it is surrounded by good intentions and it is fascinating because it is technological and computerized.

However, the poison is certainly there because the system is beyond every democratic check on the procedures and on the results obtained by the vote. Even if we could be 100 percent sure there are no errors nor fraud in the whole electoral system (humans & machines, inside our country and abroad we should accept any result without any chance of verifying it. Without such checks, it will be sitting governments to declare the winners and the losers without any possibility of being checked themselves or contradicted, and we can't forget that those who own the computers can alter any data they contain. electronic vote can be the end of democracy (as we know it now).

Not to be duped we, the people, must lift e-vote debate from the technical arena up to the arena of basic principles we all understand, the arena where we all are able to answer the question: "do we accept to trust unverifiable electronic votes or do we prefer to use verifiable ballot papers and public and repeatable procedures?"

We, the people, should reject electronic voting and pretend to use ballot papers publicly hand-counted because this is the only way we can verify that results are fair and square. People having even the smallest doubt about e-voting should apply the precautionary principle to elections and demand the use of ballot papers.

Endorsing the Precautionary Principle as a Public Health ToolPreventing Harm from Persistent Bioaccumulative Toxic Chemicals(PBTs)

[Rachel's introduction: These are "talking points" used within the Washington State Public Health Association (WSPHA) by advocates for the precautionary principle, which the WSPHA adopted Oct. 16.]

* All children of Washington State having an equal right to conditions that ensure they can reach and maintain their full potential

* Knowledge confers an ethical responsibility and duty to make decisions that promote and maintain human and environmental health, thereby preventing disease, illness or disability

* The precautionary principle holds that when an activity threatens harm to human health or to the environment, precautionary measures should be taken, even if cause-and- effect relationships are not fully established scientifically

* Precautionary Principle, which consists of four basic elements: 1) taking preventive action in the face of uncertainty, 2) shifting the burden of responsibility of safety to the proponents of an activity; 3) exploring and implementing safer alternatives to possibly harmful actions, and 4) increasing public participation in decision making;

* Taking precautionary action is the common sense idea behind many adages, such as "be careful", "better safe than sorry" and "look before you leap"

* The precautionary principle is a highly effective decision- making tool for reducing negative and costly effects on human health resulting from exposure to environmental toxicants

* The precautionary principle has been endorsed by the American Public Health Association (APHA), with the APHA stating that it "Reaffirms its explicit endorsement of the precautionary principle as a cornerstone of preventive public health policy and practice."

Rachel's Precaution Reporter offers news, views and practical examples of the Precautionary Principle, or Foresight Principle, in action. The Precautionary Principle is a modern way of making decisions, to minimize harm. Rachel's Precaution Reporter tries to answer such questions as, Why do we need the precautionary principle? Who is using precaution? Who is opposing precaution?

We often include attacks on the precautionary principle because we believe it is essential for advocates of precaution to know what their adversaries are saying, just as abolitionists in 1830 needed to know the arguments used by slaveholders.

Rachel's Precaution Reporter is published as often as necessary to provide readers with up-to-date coverage of the subject.

As you come across stories that illustrate the precautionary principle -- or the need for the precautionary principle -- please Email them to us at rpr@rachel.org.